PCD x STEP Isle of Man Conference — The Comis Hotel, 6 May 2026

The closing panel of the day brought together the property market, the law and the structuring world to examine a UK real estate landscape that is shifting faster than at any point in recent memory. For high net worth investors and the advisers serving them, the question is no longer simply where to buy — it is which asset class, through what structure, and via which jurisdiction.

The panel featured Matt Hobbs of Knight Frank, Thomas Pearson of JMW, Paul Bricknell of Kuits and Rob Cattle of Equiom, whose perspective on Isle of Man structuring for UK real estate provided the session's most actionable content.

The Renters Rights Act: A New Baseline

Matt Hobbs opened with a brief orientation on the Renters Rights Act, which came into force on 1 May — just five days before this conference. The headline change is the abolition of the Section 21 no-fault eviction notice, replaced by 37 grounds for possession under Section 8. All tenancies are now periodic from day one; rent increases are capped at once per year via a formal process; and tenants have a statutory right to request a pet unless a superior lease prohibits it.

The practical consequence is predictable: private landlords are exiting. The regulatory burden, combined with successive adverse tax changes over the past decade, has made small-scale residential property investment progressively less viable. Large build-to-rent operators, by contrast, are treating the Act as business as usual — the complexity plays to their scale. The direction of travel for high net worth investors, the panel agreed, is firmly towards commercial property, where compliance obligations sit with the tenant and management intensity is substantially lower.

Where HNW Capital Is Going: Commercial, Niches and Repurposing

The shift from residential to commercial among private wealth clients is well underway, but it is not uniform. Supported living — small residential properties for adults with care needs, let on local authority guaranteed rents — was flagged as an active growth niche: lower yield than institutional commercial, but with government-backed income and the landlord free of day-to-day management responsibility. Build-to-rent, meanwhile, is drawing in offshore institutional capital, including a Middle Eastern fund investing into a high-end office-to-residential conversion in Chester.

Thomas Pearson drew on his attendance at MIPIM in March to map the shifting asset class landscape. MIPIM draws a genuinely global audience, with UK attendees representing around a fifth of the total, making it a reliable barometer of international investor sentiment toward UK real estate. The surprise of 2026: retail came fourth in the top ten sectors that investors came to discuss — not as a recovery of the traditional shopping centre model, but through entrepreneurial repositioning.

Groups like Sports Direct are acquiring retail space to repurpose it; developers are stripping back old shopping centres to deliver food and beverage, residential and ground-floor retail in mixed-use formats. Oxford Street, Chester and Manchester's Deansgate corridor were all cited as live examples of this transformation.

The office market is undergoing a similar evolution. Outside London — where there remains a Tuesday-to-Thursday bias for in-person attendance — regional offices are seeing full occupancy. The investment angle is the permitted development route: acquiring offices quickly and repositioning them into residential under permitted development rights before planning permission requirements bite. Pearson noted he had completed four such deals in the previous month alone.

The Isle of Man Structuring Advantage: Rob Cattle, Equiom

The most concrete case for Isle of Man structuring came from Rob Cattle of Equiom, whose articulation of the jurisdiction's practical advantages over its Channel Islands competitors was precise and compelling.

The headline differentiator is VAT. The Isle of Man is plugged directly into the UK VAT system under a shared VAT agreement, meaning commercial property transactions can obtain VAT registration through the IOM interface typically within five to six working days. A Jersey or Guernsey company purchasing UK commercial property must apply to HMRC directly and can wait up to 12 weeks. On a live transaction involving a transfer of concern, that delay is not an administrative inconvenience — it can threaten the deal entirely, requiring funds to sit in escrow while registration resolves.

"I always say that VAT in the Isle of Man is really important," Cattle said. "And just because historically we've had lots of commercial property in the Isle of Man, we've got the expertise here and we're ready to do a good job — and to work until the deal is done." The commitment to seeing transactions through — including through the night when required — was a point of genuine professional pride.

On structuring vehicles, Cattle outlined the full toolkit available through the IOM. Exempt funds — an almost family-office-style pooling vehicle — can accommodate up to 49 investors in the Isle of Man while remaining outside the regulated fund regime, compared to a maximum of two in Jersey before more onerous requirements kick in. SPVs remain the workhorse for foreign nationals seeking IHT protection on UK commercial property holdings, since owning an IOM asset rather than the UK asset directly sits outside the relevant property regime. And where property sits alongside other family wealth, trust structures remain appropriate — with the asset held either directly or through an SPV beneath the trust.

Cattle also made the governance argument with particular force. When a commercial property is sold via a corporate sale — selling the SPV or fund rather than the asset itself, saving stamp duty land tax relative to a direct asset purchase — the quality of the underlying file becomes commercially significant. Clean documentation, properly recorded trustee and director decisions, and a clear audit trail of advice received can materially accelerate the buyer's due diligence and reduce the risk of the transaction falling over. "If you have a really good clean file, it makes the due diligence process for that corporate sale much more straightforward," he said.

On financing, Cattle noted that Equiom proactively monitors structures approaching the end of their lending cycle and goes to market ahead of time to ensure competitive tension among lenders. ESG credentials are increasingly shaping lending terms — developments without the right energy performance and sustainability ratings are attracting higher borrowing costs, a trend only likely to intensify.

His closing message to advisers in the room was direct: "Consider the Isle of Man when advising your clients on how to structure their property deals. There are tangible differences between the IOM and the Channel Islands, and a lot of intangible reasons why the Isle of Man is a good jurisdiction to use. Anyone who wants to talk through those specifics — I'm here tonight."

Corporate Sales, SDLT and the Legacy Envelope Problem

Thomas Pearson expanded on the mechanics of corporate sales. Selling the company that owns the property — rather than the property itself — means the transaction is subject to stamp duty at approximately 0.5% for a UK company or potentially 0% for a non-UK company, rather than the much higher stamp duty land tax rates on a direct asset purchase.

Pearson noted that such corporate acquisitions via share purchase agreement have at times attracted public criticism, including where local government and pension schemes have acquired assets held in offshore companies. The criticism, he argued, is largely misplaced: these structures are typically already in place, are entirely commonplace in the market, and carry legitimate commercial rationale — namely avoiding a significant SDLT liability on a transaction where the offshore structure pre-exists the deal and it makes commercial sense to trade within it.

Paul Bricknell of Kuits brought the tax investigation perspective to the legacy residential picture. The Annual Tax on Enveloped Dwellings (ATED) has been a persistent charge on family homes held in corporate structures, and for many years families absorbed the annual cost because the exit bill felt prohibitive. That calculus is changing: clients who have paid ten years of ATED charges are increasingly concluding that the one-off exit cost is well worth the payback, particularly where the property carries a short remaining lease that can only be extended once it leaves the structure. Nuance around the timing of lease extension notices — which must be served before the de-enveloping is completed — makes specialist advice essential.

Bricknell also sounded a warning on structures domiciled in less familiar jurisdictions. Two live cases illustrated the point: a Turks and Caicos company and a Liechtenstein structure, both causing significant difficulty — one unresponsive and creating uncertainty around liquidity for a client wanting to transact, the other so opaque that HMRC itself had to escalate to senior legal counsel before it could confirm the tax treatment. His conclusion was unambiguous: "Use structures in jurisdictions that English lawyers can understand, where you're going to be well regulated and get a higher level of service. For us in the Northwest, the Isle of Man is the natural bedfellow."

Club Deals, Family Structures and the Succession Conversation

The panel closed with a discussion of how families are pooling capital into property. Bare trust syndication structures — particularly active within certain professional communities — allow 10 to 15 investors to participate under a single vehicle that is tax transparent, with each investor managing their own tax position independently. Family investment companies remain the default for pure family plays, though Pearson cautioned that they need periodic review: a grandchild relocating to the US can unravel the structure's tax efficiency overnight.

Matt Hobbs offered a perspective that stepped back from the technical. Many clients have accumulated substantial residential portfolios over decades and are now transitioning — not just into commercial property, but out of active management entirely. The conversations he is increasingly having are about purpose: whether to add another asset, or to use capital to get grandchildren onto the property ladder now rather than via inheritance later. "Why not enjoy seeing your grandchildren benefit while you're still here?" he said. It is a wealth planning conversation wearing property clothes.

Session 4 was moderated by David Bell. Panellists: Matt Hobbs (Knight Frank), Paul Bricknell (Kuits), Thomas Pearson (JMW) and Rob Cattle (Equiom).